Page 375 - International Taxation IRS Training Guides

Key Provisions of Tax Treaties:

Administration (Cont’d)

Advance Pricing Agreements (APAs)

 An APA may be concluded on a bilateral or

basis between CAs through the mutual
multilateral

procedure of the relevant treaty
agreement

APA is an agreement between tax
 A bilateral
administrations
and a Taxpayer on the proper transfer

pricing of related party cross-border
transactions for a

term
of years, which often include prior years as well
as
future years

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